European Union Privacy Policy (Get Grab Limited)

Grab Privacy Policy

Effective Date: September 24, 2018

The Grab website (the “Website”) and mobile application (the “App”) (collectively, the “Grab Properties”) are brought to you by Cursus Technologies, Inc. (“Cursus”). In this Privacy Policy (this “Policy”), we describe how we collect, use, and disclose information that we obtain through your use of the Grab Properties, and we tell you about your privacy rights and how the law protects you.

By visiting the Website and/or downloading the App, you acknowledge that your personal information will be handled as described in this Policy. Your use of the Grab Properties, and any dispute over privacy, are subject to this Policy and our Terms of Use, which are incorporated by reference into this Policy and include applicable limitations on damages and the resolution of disputes.

These are early release versions of the Grab Properties; we may update and change this Policy and the Grab Properties from time-to-time. We reserve the right to change the terms of this Policy at any time. When we do, we will post the revised Policy to our Website and App, and the last revision date of revision will be updated so that you will always be able to understand what information about you we collect, how we use your information, and under what circumstances we may share your information with others. We will notify you of any material changes by email announcing that this Policy has changed, and pointing the changes to your attention. You may be required to read and accept the changes to continue your use of the App.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Our Website and App are not intended for children under 18 years of age. No one under age 18 may provide any information to or on our Website or App. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Website or App, on or through any of their features, or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@getgrab.com.

Controller

Cursus is made up of two different legal entities, details of which can be found below:

Get Grab Limited, c/o Legalinx, One Fetter Lane, London EC4A 1BR, United Kingdom. Get Grab Limited is a wholly owned subsidiary of Cursus Technologies, Inc.

This Policy is issued on behalf of the Cursus Group so when we mention “Cursus”, “we”, “us” or “our” in this Policy, we are referring to the relevant company in the Cursus Group responsible for processing your information.

You also have the right to make a complaint at any time to your national supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

The Information We Collect About You

Information, data, personal information, or personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect information about you directly from you and from third parties as further set out below, as well as automatically through your use of the Grab Properties. We have grouped together below the various categories of personal information about you we may collect, use, store and transfer:

Identity Data includes first name, maiden name, last name, username or similar identifier.

Transaction Data includes details about payments to and from you and other details of in-App purchases.

Technical and/or Device Data includes, from the Website, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website and, from the App, the type of mobile device you use, mobile network information, your mobile operating system, the type of mobile browser you use, country setting, time zone setting, language setting

Content Data includes the ratings and reviews you provide on orders you place via the Grab Properties.

Usage Data includes details of your use of our App or your visits to our Website including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Location Data includes your current location disclosed by GPS, Bluetooth and indoor location services such as Apple co-location technology as well as your destination location which you manually enter into the App or which we received about you from one of our App integration partners when you connect to their App that embeds our technology.

We may combine the information that we collect, whether directly from you, automatically, or from social networks for the reasons set out in the How We Use Your Information section below.

How is your information collected

We will collect and process the following information about you:

Information We Collect Directly From You.

We collect Identity, Contact, Financial, and Marketing and Communications Data directly from you when you register with us, place an order, request information from us, or otherwise contact us. The type of information that we collect from you depends on your interaction with the Grab Properties.

Information that We Collect About You from Social Networking Sites.

You may log into the App or the Website using your Facebook and other social networking site credentials. If you do so, we will request permission from you to access the following information about you: (i) your name; (ii) user ID; (iii) e-mail address; and (iv) profile photo.

Where you use third-party social networking sites, the third-party social networking site also controls the information it collects from you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.

Information We Collect Automatically.

We automatically collect information about your use of the Grab Properties through cookies, web beacons and other technologies, including but not limited to Location, Usage, and Technical and/or Device Data.

Important Note: These Grab Properties will continue to process your Location Data through beacons and other technologies even when you are not using the Grab Properties.You will be asked to consent to your Location Data being used for purposes described in the “How We Use Your Information” section below. You can withdraw your consent at any time by sending an email to marketing@getgrab.com.

Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Information We Collect About You From Other Sources.

We may obtain the following information about you from third-party sources and public sources as set out below:

Technical and/or Device Date from analytics providers such as Google based outside the EU;

Transaction Data from payment processing providers such as Braintree, a PayPal subsidiary based outside the EU;

Location Data from our integration partners who integrate our technology within their app.

We also collect, use and share Aggregated Information such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate information about how your use our Grab Properties to calculate the percentage of users accessing a specific feature on such properties. However, if we combine or connect Aggregated Information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this Policy.

We do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the ability to place an order through the App). In this case, we may have to cancel an order you have placed with us but we will notify you if this is the case at the time.

How We Use Your Information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where you have consented before the processing

Where we need to perform the contract we are about to enter into or have entered into with you for the purchase of goods we offer for sale through our App.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Please check our Glossary at the end of this Policy to find out more about the types of lawful basis that we will rely on to process your personal information.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us at privacy@getgrab.com if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity

Type of information

Lawful basis for processing including basis of legitimate interest

To install the App and register you as a new user of our App

Identity

Contact

Financial

Technical and/or Device

Performance of a contract with you

To process in-App purchases, send you updates about your order (including through push notifications and text messages, at your election), deliver your order including managing payments, fees and charges, and collecting money owed to us.

Identity

Contact

Financial

Transaction

Technical and/or Device

Marketing and Communications

Location

Your consent (for push notifications and text messages)

Performance of a contract with you (process in-App purchases, send you updates about your order, deliver your order, and manage, including collect payments, fees and charges)

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

To deliver relevant website and/or App content, promotion offers, and advertisements to you, including through postings to your Facebook Wall and other social sharing properties

To make suggestions and recommendations to you based on your location about products and/or services that may be of interest to you

To measure or analyze the effectiveness of the advertising we serve to you

To monitor trends so we can improve the Website and App

Identity

Contact

Content

Profile

Technical and/or Device

Content

Usage

Marketing and Communications

Location

Consent (to geo-locate you)

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. Through your user account on our Grab Properties you can view and make certain decisions about your personal information use.

Promotional offers from us

We may use your Identity, Contact, Technical and/or Device, Usage, Location, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from merchants through our Grab Properties and you have not opted out of receiving that marketing.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Third-party marketing and advertising

We may share your personal information with third parties for marketing and advertising purposes on our App or on the Website. For example, we may share your information with third parties, such as merchants and airport operators that wish to run an ad promoting their products or services that are available for sale via the Grab Properties, or that wish to encourage you to use the Website or download and use the App.

We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website or App and by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product or service purchase, warranty registration, product or service experience or other transactions.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How We Share Your Information

When you consent to providing us with your personal information, we will also ask you for your consent to share your personal information with the third parties set out below for the purposes set out in the table above:

Affiliates. We may disclose the information we collect from you to our affiliate based in the United States.

Service Providers. We disclose your information to third party vendors, service providers, contractors or agents acting as processors based inside and outside the EU, who perform administrative and operational functions on our behalf, however, if we do so, their use and disclosure of your information will be governed by a contract requiring them to only use and disclose data in accordance with this Policy. We may also share your information with third party service providers to enable those service providers to: (i) process and fulfill your orders; and (ii) review and analyze statistical information pertaining to the Website and/or App.

Professional advisers acting as processors or joint controllers, including lawyers, and auditors based in the UK and the U.S. who provide legal, tax and accounting services.

Regulators and other authorities acting as processors or joint controllers based in the EU and the U.S. who require reporting of processing activities in certain circumstances.

In addition, we may process or share your information in the following circumstances:

Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to that other company.

In Response to Legal Process. To comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena or to establish, exercise or defend legal claims.

To Protect Us and Others. Where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.

Aggregate and De-Identified Information. We may share aggregate or de-identified information with third parties to assist us in our own marketing, advertising, research or similar purposes.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Please contact us at privacy@getgrab.com if you want further information on the specific third party recipients with whom we may share your personal information and the purpose(s) for such sharing.

Our Use of Cookies and Other Tracking Mechanisms

We use cookies and/or other tracking technologies to distinguish you from other users of our Website and App, and to remember your preferences. This helps us to provide you with a good experience when you use the Website and/or App or browse our Website and/or App and also allows us to improve the App and Website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

Plug-ins and Social Media Widgets.

The Grab Properties may include social media features and widgets, such as the Facebook Like button and the “Share this” button, as well as other interactive mini-programs that run on the Website and/or App and enable certain features to work (e.g., content sharing and comments). These features may collect your IP address and other usage information. These features are subject to their own privacy policies, not this one.

Do-Not-Track

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

Third-Party Links

Our Website and/or App may contain links to third-party websites or allow you to post content to (or transmit content to) third-party websites, including without limitation to perform commercial transactions. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Please note that we also do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads by visiting the website of the European Interactive Digital Advertising Alliance (“EIDAA”) at https://www.edaa.eu as well as of the European Advertising Standards Alliance (“EASA”) at http://www.easa-alliance.org.

International Transfer of My Personal Information

We are an international business and so we transfer personal data all over the world as part of our business operations and in order to provide the Grab Properties and run our business. Where we transfer personal information outside of Europe, we use one or more of the following mechanisms in place:

Where we transfer the information to our affiliate in the U.S. or when we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the U.S., we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the U.S. For further details, see European Commission: EU-US Privacy Shield.

Security of My Personal Information

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or OAUTH 2.0. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website or App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way.

We will collect and store personal information on your computer or mobile device using [application data caches and browser web storage (including HTML5) and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please contact us at privacy@getgrab.com if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA, or if you want to know more about the security measures we have implemented to protect your personal information.

Information retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your information: see Request erasure below for further information.

In some circumstances, we will anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

My Rights in relation To My Personal Information

If we require you to register with us, you may modify personal information that you have submitted by logging into your account and updating your profile information. Copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website and/or App for a period of time.

In addition, under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows.

Request access to your personal information.

Request correction of your personal information.

Request erasure of your personal information.

Object to processing of your personal information.

Request restriction of processing your personal information.

Request transfer of your personal information.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@getgrab.com.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional emails to you where you have consented to receiving such emails or as otherwise legally permitted. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any products or services you have requested or received from us. Where you have consented to us sharing your information with third parties for marketing purposes, you may continue to receive messages from third parties, unless you opt-out from such messages through the applicable third party. If you take advantage of a third party offer that has been sent to you, that third party may collect certain information from you, subject to its own privacy policy.

To cease the collection of your information by the Website and/or App, you will need to delete the App from your mobile device or log off from the Website (as applicable). Deletion of the App or logging off from the Website will not cease our use of the information that has already been collected by the App or the Website pursuant to this Policy.

This App will send you push notices. You may turn off push notices for this App through the phone settings screen or the App’s settings.

With regard to account activity-related text messages sent to your phone, after activation, reply with STOP or go into the App’s settings to opt-out. Reply HELP for help. Message & Data rates may apply. The number of text messages you receive may vary based on your account activity.

GLOSSARY

LAWFUL BASIS

Consent means processing your personal information where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.

YOUR RIGHTS IN RELATION TO INFORMATION WE HOLD ABOUT YOU

You have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:

If you want us to establish the information’s accuracy.

Where our use of the information is unlawful but you do not want us to erase it.

Where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products and/or services to you. We will advise you if this is the case at the time you withdraw your consent.

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